The legislation uses the heading ‘sales treated as being for alternative amount’ to cover both an anti-avoidance rule and a tax planning opportunity. The overall effect of the legislation can be summarised as follows (but subject to the more precise details given after the summary).
•First, there are tax avoidance rules that require market value to be substituted for actual proceeds where certain transactions are designed primarily to reduce a person’s tax liability.
•Second, there is a requirement to substitute market value for the actual proceeds figure in certain transactions between (broadly) connected parties.
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